Counsellor Tutor Ltd (company registration number: 09769637) (we, us, our) is committed to protecting the privacy and security of your personal data. This Privacy Notice describes how we collect, use and look after your personal data when you visit our website, www.counsellingtutor.com, (Site) (regardless of where you visit it from), register for an account and/or purchase the training services which we provide from time to time (Services). It also tells you about your rights and how the law protects you.

1 Important information

1.1 Supplemental Terms - This Privacy Notice supplements the other notices and terms published on our Site (including our Terms and Conditions of Service and Cookies Policy (Terms)) and is not intended to override them.

1.2 Controller - We are the controller of, and are responsible for, your personal data.

1.3 Understanding - To assist you further in understanding this Privacy Notice, we have set out in the Schedule a glossary of terms used in this Privacy Notice, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.

1.4 Questions - If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us in writing, either by:

Email: support@counsellingtutor.com
Post: Devonshire House, 582 Honeypot Lane, Stanmore, Middlesex, United Kingdom, HA7 1JS

1.5 Complaints - You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Click to see our complaints policy.

1.6 Who can use our Site – Our Site is not intended for children, and we do not knowingly collect data relating to children.

1.7 Changes to this Privacy Notice - We may change this Privacy Notice from time to time by updating this page. Please check it regularly to ensure you are aware of any changes.

1.8 This Privacy Notice was created in February 2023.

1.9 Changes to your personal data - It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.

1.10 Third-party links - Our Site may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control over these third-party websites, plug-ins or applications and are not responsible for their privacy notices, therefore you should read their privacy notices to understand what personal data they collect about you and how they use it.

 

2 The data we collect about you

2.1 We may collect, use, store and transfer the types of personal data about you listed in Part 1 of the Schedule.

2.2 We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.

2.3 We do not collect any special categories of personal data or any information about criminal convictions and offences.

2.4 Failure to provide personal data - If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it:

2.4.1 we may not be able to enter into or perform the contract with you; and/or

2.4.2 we may have to cancel a product and/or the contract (as applicable).

We will notify you of this at the relevant time.

 

3 How personal data is collected

We collect personal data in the following ways:

Direct interactions	You may provide personal data when you order the Services from our Site or otherwise correspond with us (by post, phone or email).
Automated technology	We automatically collect personal data (technical and usage) when you browse or interact with our Site, by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies. Please see our Cookies Policy Cookie Policy • Counselling Tutor for further details.
Publicly available sources	We may collect personal data from publicly availably sources such the Electoral Register and credit reference agencies, based inside the UK.
Third parties	We may receive personal data from: (a) analytics providers; (b) advertising networks; (c) search information providers; and (d) our suppliers such as website support and maintenance providers.

 

4 How we use your personal data

4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:

4.1.1 to perform the contract we are to enter into or have entered into with you, in relation to your purchase of the Services which we provide;

4.1.2 to comply with a legal obligation; or

4.1.3 where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

4.2 Part 2 of the Schedule sets out the lawful basis we will rely on to process your personal data.

4.3 Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information.

4.4 Marketing - You will only receive marketing communications from us, if you have:

4.4.1 purchased Services from us;

4.4.2 downloaded a handout or any other content from our Site;

4.4.3 you have provided your consent to receive marketing communications

and have not opted out of receiving marketing communications, unsubscribed from our mailing list or withdrawn your consent.

4.5 We will not share your personal data with third parties for their marketing purposes.

4.6 How to opt out - You can opt out of email marketing by clicking the unsubscribe button within the particular marketing email. You can also withdraw your consent to receive marketing communications and asked to be removed from our mailing list at any time by contacting us.

4.7 Even if you opt out of receiving marketing communications, we may still use your personal data for other purposes provided we have a lawful basis to do so.

4.8 Change of purpose - We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose or we have a lawful basis to change the purpose.

4.9 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to use your personal data in this manner.

4.10 We may process your personal data (without your knowledge or consent) where this is required or permitted by law.

 

5 Disclosure of your personal data

We may share your personal data with the Third Parties set out in Part 4 of the Schedule. We require all Third Parties to respect the security of your personal data and to treat it in accordance with the law. Such Third Parties can only process your personal data for specified purposes and in accordance with our instructions.

 

6 International transfers

6.1 Some Third Parties may be based outside of the UK, therefore your personal data may be transferred outside of the UK.

6.2 Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

6.2.1 we will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data;

6.2.2 we use specific contracts which give personal data the same protection it has in the UK with our services providers.

 

7 Data security

7.1 We operate appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to personal data is restricted to individuals who have a business need to know it, are under confidentiality obligations and can only process it on our instructions.

7.2 We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8 Data retention

8.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

8.2 We may update our data retention practices from to time and you can request details by contacting us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after the end of the tax year in which they cease being customers, for tax purposes.

8.3 We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.

 

9 Your legal rights

9.1 Your legal rights in relation to your personal data are set out in full in Part 3 of the Schedule. If you wish to exercise any of your rights, please contact us.

9.2 You will not have to pay a fee to exercise any of your rights unless your request is clearly unfounded, repetitive or excessive. In which case, we may charge a reasonable fee for this information or refuse to comply with your request.

9.3 We may ask you to provide further information to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.

9.4 We aim to respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests it may take us longer to respond. In this case, we will notify you and keep you updated.